ArticleFidelity Funds vs The Danish Ministry – CJEU Rules In Favour Of TaxpayersThe UCITS has the status of Article 16C of the law on the assessment of income tax LuxembourgTaxAtoz Tax Advisers
ArticleNew CRS And FATCA Legislation: A Real Change?In our November 2019 ATOZ blog (Upcoming FATCA - CRS Issues: What the Alternative Fund Industry Needs to Know), we noted that the Luxembourg tax authorities more frequently...LuxembourgTaxAtoz Tax Advisers
ArticlePillar Two And DAC9: Luxembourg Adopts Law Easing Filing Obligations And Clarifies Treatment Of Deferred TaxesOn 17 December 2025, the Luxembourg Parliament enacted the law on the exchange of information with respect to "top-up tax information return" (the "DAC9 Law"), which transposes...LuxembourgTaxAtoz Tax Advisers
ArticlePublic Country-By-Country Reporting Directive Adopted By The EU CouncilOn 28 September 2021, more than five years after it was first tabled, the so-called "public Country-by-Country Reporting (CbCR) directive" was finally adopted by the EU Council under qualified majority voting.European UnionTaxAtoz Tax Advisers
ArticleEU Commission Finds No Illegal State Aid In The McDonald's CaseOn 19 September 2018, the EU Commission announced its decision in the McDonald's State Aid investigations. According to a press release the Commission has found that the non-taxation...GlobalTaxAtoz Tax Advisers
ArticleEuropean Court Of Justice Rules On Spanish Withholding Tax On US RICsThe European Court of Justice has ruled on whether a foreign tax credit mechanism can neutralise discriminatory withholding tax treatment for US Regulated Investment Companies receiving dividends from Spanish listed companies. The Spanish Supreme Court must now determine if theoretical neutralisation at shareholder level can ever be achieved in practice, given the exceptionally high evidentiary bar set by the CJEU. GlobalTaxAtoz Tax Advisers
ArticleThe Bahamas, Belize, The Seychelles & The Turks And Caicos Islands Removed From The EU List Of Non-cooperative Tax JurisdictionsOn 26 February 2024, the new list of non-cooperative jurisdictions for tax purposes (the "Blacklist") was published in the Official Journal of the European Union.GlobalTaxAtoz Tax Advisers
ArticleATOZ Insights - May 2025As spring is upon us, the time has come to present our latest edition of our Insights, highlighting recent developments from the Grand Duchy, at European level, and in the Middle East over the past few months.LuxembourgTaxAtoz Tax Advisers
ArticleCJEU Decides In Danish Cases Relating To Beneficial OwnershipOn 26 February 2019, the Court of Justice of the European Union ("CJEU") issued its decisions in six cases which deal with the interpretation of the Parent-Subsidiary Directive ("PSD") and the Interest & Royalties Directive ("IRD", together the "Directives").LuxembourgTaxAtoz Tax Advisers
ArticleDAC6 – Luxembourg Implements The New Reporting Obligations Of Tax IntermediariesOn Saturday 21 March 2020, the Luxembourg parliament passed the law implementing the Council Directive (EU) 2018/822 of 25 May 2018 ("DAC6") regarding the mandatory exchange of ...LuxembourgTaxAtoz Tax Advisers
ArticleECOFIN Council Reaches An Agreement On DAC8At yesterday's ECOFIN meeting, the EU Council agreed on a general approach regarding foreseen amendments to the directive on administrative cooperation in the area of taxation.LuxembourgTaxAtoz Tax Advisers
ArticleEU List Of Non-Cooperative Jurisdictions For Tax Purposes Confirmed By The EU CouncilDuring today's ECOFIN meeting, the EU Council has reaffirmed the EU list of noncooperative jurisdictions for tax purposes ("Blacklist").LuxembourgTaxAtoz Tax Advisers
ArticleThe Amended Luxembourg Tax Consolidation Regime: Improvements Still NeededThe 2021 budget law dated 19 December 2020 introduced a new provision dealing with the tax consolidation regime with effect as from tax year 2020. LuxembourgTaxAtoz Tax Advisers
ArticleNew Rules For EU Cross-border Conversions And Divisions Of CompaniesYesterday, the law of 17 February 2025 (the "New Law") transposing the Directive (EU) 2019/2121 of the European Parliament and of the Council of 27 November 2019 (the "Mobility Directive")...LuxembourgCorporate/Commercial LawAtoz Tax Advisers
Article2019 Tax ForecastsThe ratification procedures of the new France-Luxembourg tax treaty and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS ("MLI") ...LuxembourgTaxAtoz Tax Advisers
Article2020 Corporate Tax Returns: More Tax Rules, More Reporting, Time For Action!On 4 May 2021, the Luxembourg tax authorities informed Luxembourg taxpayers about the release of the corporate tax forms and related appendices in respect of tax year 2020.LuxembourgTaxAtoz Tax Advisers
ArticleCorporate Tax Reform 2019 – Part IIOn 5 March 2019, the 2019 budget draft law was presented to Parliament.LuxembourgTaxAtoz Tax Advisers
ArticleLuxembourg Government Submits Draft Law Introducing A Single Tax Class For Individual Taxpayers From 2028On 6 January 2026, the Luxembourg government released draft law No. 8676 (the "Draft Law") introducing a single tax class for income taxation...LuxembourgTaxAtoz Tax Advisers
ArticleTax Treatment Of Contributions To Account 115: Decision Of The Luxembourg TribunalOn 11 May 2021, the Luxembourg Administrative Tribunal ruled on whether contributions to "account 115" have to be taken into account when computing the acquisition price of a shareholding for the application of the participation exemption regime.LuxembourgTaxAtoz Tax Advisers
ArticleApple Case: EU Judges Confirm That The European Commission Had It WrongOn 15 July 2020, in the Apple case, the EU judges (General Court) concluded for the second time in less than one year that the EU Commission failed to demonstrate that by issuing a tax ruling dealing with transfer pricing matters, ...European UnionTaxAtoz Tax Advisers